PROFORM INTERIORS PRIVATE LIMITED,GURGAON vs. DCIT CC-20, NEW DELHI

u/s 147 and for the remaining two\nyears i.e., Assessment Years 2021-22 and 2022-23 assessment orders were passed\nu/s 143(3) of the Act. By Finance Act 2021, section 148 has been amended and as\nper the new section limitation were provided in section 149 where section 149(1) (b)\nfirst proviso provided as under:\n“Provided that

PROFORM INTERIORS PRIVATE LIMITED,GURGAON vs. DCIT CC-20, DELHI

In the result, all the appeals for

u/s 147 and for the remaining two\nyears i.e., Assessment Years 2021-22 and 2022-23 assessment orders were passed\nu/s 143(3) of the Act. By Finance Act 2021, section 148 has been amended and as\nper the new section limitation were provided in section 149 where section 149(1) (b)\nfirst proviso provided as under:\n“Provided that

PROFORM INTERIORS PRIVATE LIMITED,GURGAON vs. DCIT CC-20, NEW DELHI

In the result, all the appeals for

u/s 147 and for the remaining two\nyears i.e., Assessment Years 2021-22 and 2022-23 assessment orders were passed\nu/s 143(3) of the Act. By Finance Act 2021, section 148 has been amended and as\nper the new section limitation were provided in section 149 where section 149(1) (b)\nfirst proviso provided as under:\n“Provided that

PROFORM INTERIORS PRIVATE LIMITED,GURGAON vs. DCIT CC-20, DELHI

u/s 147 and for the remaining two\nyears i.e., Assessment Years 2021-22 and 2022-23 assessment orders were passed\nu/s 143(3) of the Act. By Finance Act 2021, section 148 has been amended and as\nper the new section limitation were provided in section 149 where section 149(1) (b)\nfirst proviso provided as under:\n“Provided that

PROFORM INTERIORS PRIVATE LIMITED,GURGAON vs. DCIT CC-20, NEW DELHI

u/s 147 and for the remaining two\nyears i.e., Assessment Years 2021-22 and 2022-23 assessment orders were passed\nu/s 143(3) of the Act. By Finance Act 2021, section 148 has been amended and as\nper the new section limitation were provided in section 149 where section 149(1) (b)\nfirst proviso provided as under:\n“Provided that

PROFORM INTERIORS PRIVATE LIMITED,GURGAON vs. DCIT CC-20, NEW DELHI

In the result, all the appeals for Assessment Years 2013-14 to 2022-23 in ITA

Bench: Shri Anubhav Sharma & Shri Manish Agarwalita Nos. 4153 & 4008/Del/2025 (Assessment Year: 2012-13 & 2018-19) Dcit, Proform Interiors Pvt. Ltd., Central Circle-20, Ground Floor, Jmd Regent Room No. 269A, 2Nd Floor, Vs. Plaza, Mg Road, Gurgaon, Ara Centre, Jhandewalan Haryana-122001. Extn., Delhi-110055. Pan-Aahcs5999J

147 and for the remaining two years i.e., Assessment Years 2021-22 and 2022-23 assessment orders were passed u/s 143(3) of the Act. By Finance Act 2021, section 148 has been amended and as per the new section limitation were provided in section 149 where section 149(1) (b) first proviso provided as under: “Provided that no notice

PROFORM INTERIORS PRIVATE LIMITED,GURGAON vs. DCIT CC-20, NEW DELHI

u/s 147 and for the remaining two\nyears i.e., Assessment Years 2021-22 and 2022-23 assessment orders were passed\nu/s 143(3) of the Act. By Finance Act 2021, section 148 has been amended and as\nper the new section limitation were provided in section 149 where section 149(1) (b)\nfirst proviso provided as under:\n“Provided that

PROFORM INTERIORS PRIVATE LIMITED,GURGAON vs. DCIT CC-20, NEW DELHI

In the result, all the appeals for

u/s 147 and for the remaining two\nyears i.e., Assessment Years 2021-22 and 2022-23 assessment orders were passed\nu/s 143(3) of the Act. By Finance Act 2021, section 148 has been amended and as\nper the new section limitation were provided in section 149 where section 149(1) (b)\nfirst proviso provided as under:\n“Provided that

BEST BULL STOCK TRADING PVT LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE-18, NEW DELHI

In the result, the appeals of the revenue in ITA No

Bench: Sh. C.N. Prasad & Sh. M. Balaganesh

B" i.e. person other than "A". 4. That on the facts & circumstances of the case and in law, the CIT(A) did not appreciate that since no incrementing material was found during search allegedly conducted on the Appellant, therefore, direction to initiate proceedings under section 147 of the Act, for the assessment year 2015-16 was beyond the scope

BEST BULL STOCK TRADING PVT LTD.,NEW DELHI vs. ACIT CENTRAL CIRCLE-18, DELHI

In the result, the appeals of the revenue in ITA No

Bench: Sh. C.N. Prasad & Sh. M. Balaganesh

B" i.e. person other than "A". 4. That on the facts & circumstances of the case and in law, the CIT(A) did not appreciate that since no incrementing material was found during search allegedly conducted on the Appellant, therefore, direction to initiate proceedings under section 147 of the Act, for the assessment year 2015-16 was beyond the scope

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-19, DELHI, NEW DELHI vs. M/S JKM INFRA PROJECTS LTD., NOIDA, UTTAR PRADESH

In the result, the appeal of the revenue is dismissed and Cross

Bench: Shri M. Balaganesh & Shri Sudhir Kumaracit, Vs. M/S. Jkm Infra Projects Ltd, Central Circle-19, Sector-9, Noida Delhi Maharishinagar, Maharishi Nagar, So Gautam Budh Nagar, Up 201304 (Appellant) (Respondent) Pan: Aabcj3577H Co 132/Del/2025 (In Ita No. 3031/Del/2025) (Assessment Year: 2013-14) M/S. Jkm Infra Projects Ltd, Vs. Acit, Sector-9, Noida Central Circle-19, Maharishinagar, Maharishi Delhi Nagar, So Gautam Budh Nagar, Up 201304 (Appellant) (Respondent) Pan: Aabcj3577H

147, section 148, section 149, section 151 and section 153, in the case of a person where a search is initiated under section 132 or books of account, other documents or any assets are requisitioned under section 132A after the 31st day of May, 2003 [but on or before the 31st day of March, 2021], the Assessing Officer shall

SEEMA GOEL,DELHI vs. CIT A, DELHI

The appeals of the assessee are allowed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

1) On the facts and circumstances of the case, the learned CIT(A) has erred both on facts and in law in confirming the action of the AO despite the fact that the order under Section 148A(d) of the Act, notice under section 148 of the Act and the consequent reassessment order under section 147 r.w.s

SEEMA GOEL,DELHI vs. CIT A, DELHI

The appeals of the assessee are allowed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

1) On the facts and circumstances of the case, the learned CIT(A) has erred both on facts and in law in confirming the action of the AO despite the fact that the order under Section 148A(d) of the Act, notice under section 148 of the Act and the consequent reassessment order under section 147 r.w.s

K K SPUN INDIA LIMITED,DELHI vs. DCIT, JHANDEWALAN DELHI

The appeals of the assessee are allowed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

1) On the facts and circumstances of the case, the learned CIT(A) has erred both on facts and in law in confirming the action of the AO despite the fact that the order under Section 148A(d) of the Act, notice under section 148 of the Act and the consequent reassessment order under section 147 r.w.s

K K SPUN INDIA LIMITED,DELHI vs. DCIT CENTRAL CIRCLE-2 NEW DELHI, JHANDEWALAN DELHI

The appeals of the assessee are allowed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

1) On the facts and circumstances of the case, the learned CIT(A) has erred both on facts and in law in confirming the action of the AO despite the fact that the order under Section 148A(d) of the Act, notice under section 148 of the Act and the consequent reassessment order under section 147 r.w.s

THE HISAR LEADING BANK CO-OP NON-AGRI THRIFT & CREDIT SOCIETY,HISAR vs. INCOME-TAX OFFICER, WARD-1, HISAR, HISAR

In the result, Appeal of the Assessee is allowed

147 shall\napply as they apply for the purposes of that section. (2) The\nprovisions of sub-section (1) as to the issue of notice shall\nbe subject to the provisions of section 151.\n(3) If the person on whom a notice under section 148 is to\nbe served is a person treated as the agent

ACIT, CIRCLE-26(2), NEW DELHI vs. VIKRAM ELECTRIC EQUIPMENT P.LTD, NEW DELHI

The appeal of the Revenue is dismissed as\ninfructuous

149. (1) No notice under section-148 shall be issued for\nthe relevant assessment year,—\n\n(a) if four years have elapsed from the end of the\nrelevant assessment year, unless the case falls under\nclause (b);\n\n(b) if four years, but not more than six years, have\nelapsed from the end of the relevant assessment year

DEVENDER,ALWAR vs. INCOME TAX OFFICER, REWARI

Appeal is allowed

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwal

u/s 147 r.w.s. 144 of the Income Tax Act, 1961. 2. Heard both the parties at length. Case file perused. 3. It transpires during the course of hearing that the first and foremost issue between both the parties before us is that the validity of section 148 proceedings initiated vide notice dated 04.04.2022 itself. This is for the precise reason